2004 Q&A Addendum, Question # 10

10. If a covered facility manufactures 19,000 pounds, processes 18,000 pounds, and imports 7,000 pounds of toxic chemical X (a non-PBT chemical) during the reporting year, is it required to report for toxic chemical X?
Yes. For the reporting year, the facility would have to report for toxic chemical X because it would have exceeded the manufacture threshold of 25,000 pounds (19,000 (manufactured) + 7,000 (imported) = 26,000). Note that importing constitutes manufacturing, and therefore, the amounts must be added together for threshold determinations.

Additional Details

Question # 10 Source EPCRA Section 313 Questions and Answers Addendum to the Revised 1998 Version as of December 2004 (PDF)(63 pp, 600 KB, November 2004)
ID 04-010 Status Archived
Category 1. Determining Whether or Not to Report: Facility Subcategory 1.E. Threshold Determinations
Keyword(s) Import (Imported), Manufacture (Manufactured; Manufacturing; Produce; Produced), Threshold Determination (Activity Threshold)
Updated Q&A Question Number 314
Prior Q&A [Archived] Question Number 60, 1997 EPCRA 313 Q&A
Prior Source: [Archived] Question Number 96, 1998 EPCRA 313 Q&A: Import; Manufacture; Threshold Determination.28 and therefore, Qs " As throughout the 1998 Q"A Document have been modified to account for the lower thresholds for PBT chemicals. (See Persistent Bioaccumulative Toxic (PBT) Chemicals final rule (64 FR 58666, October 29, 1999) and Lead and Lead Compounds final rule (66 FR 4500, January 17, 2001)). Revision Explanation: NA